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Memorandum to Czech Presidency and Ten Test - EEB

Memorandum to Czech Presidency and Ten Test - EEB

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<strong>EEB</strong> <strong>Memor<strong>and</strong>um</strong> <strong>to</strong> the <strong>Czech</strong> EU <strong>Presidency</strong>- A clear requirement for Member States <strong>to</strong> address current rates of soilsealing.7.7. Bring National Emission Limits DownThe National Emission Ceilings (NEC) Directive is one of the pillars of the EU’sair pollution control legislation. Its revision in 2009 will determine the muchneedednew interim air quality targets for 2020, as foreseen in the 6 thEnvironmental Action Programme, <strong>and</strong> set tighter limits on emissions of sulphurdioxide, nitrogen oxides, volatile organic compounds, <strong>and</strong> ammonia, plus firstevernational caps on emissions of fine particulate matter (PM 2.5 ), <strong>to</strong> be achievedby Member States by 2020.The directive was already due for revision in 2004 <strong>and</strong> the Commission did all theprepara<strong>to</strong>ry work. But by the middle of 2008 they decided <strong>to</strong> postpone it further <strong>to</strong>avoid annoying Member States who were deciding on the Energy/Climatepackage. In Oc<strong>to</strong>ber 2008, the <strong>Czech</strong> <strong>and</strong> Swedish environment ministers, whowill be chairing the Environment Council in 2009, called upon the Commission forimmediate adoption of the revision proposal. The ministers concluded that “newstricter ceilings leading <strong>to</strong> additional emission abatement measures are urgentlyrequired”.The longer the revision is postponed, the greater the need for updating of crucialinput data will be. In order <strong>to</strong> maintain its credibility, the whole computermodelling analysis may have <strong>to</strong> be repeated, which would lead <strong>to</strong> additional costsas well as additional delays. Moreover, Member States <strong>and</strong> industry requireadequate time frames for implementation, so any (further) delay will bedetrimental <strong>to</strong> the cost-effective implementation of the Directive. It is time forclear guidance <strong>to</strong> be given <strong>to</strong> the market, as investment portfolios addressing airpollution <strong>and</strong> climate change are unfolding now. At best, a delay will createuncertainty for these investments <strong>and</strong>, at worst, undermine <strong>and</strong> discourage them.Further postponement will also lead <strong>to</strong> a delay in other air quality laws scheduledfor presentation <strong>and</strong> adoption in 2009/10, particularly stricter emissions <strong>and</strong> fuelst<strong>and</strong>ards for marine shipping. Such a chain reaction of delays will furtherjeopardise the attainment of the objectives of the 6th EAP by failing <strong>to</strong>significantly reduce air pollution from ships on European seas <strong>and</strong> ashore.Postponement of policy proposals in the EU also has wider internationalimplications – such as slowing down revision progress under the Convention onLong-Range Transboundary Air Pollution (CLRTAP).In the course of the interim evaluation of the implementation of the NECDirective, it has become clear that current national emissions ceilings are notsufficient <strong>to</strong> meet even interim environmental <strong>and</strong> health objectives for 2010, sonew stricter ceilings are urgently needed. Data reported by 25 Member Statesshows that most will not meet the emission ceilings objectives for nitrogen33

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